Wuhan Youyou Luming Information Technology Co Ltd v. Dongguan Lianguang Electronic Technology Co Ltd

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Dongguan Puji Electronics Co., Ltd. and Wuhan Youyou Luming Information Technology Co., Ltd. (People's Republic of China)
  • Defendant: Dongguan Lianguang Electronics Technology Co., Ltd. (People's Republic of China)
  • Plaintiff's Counsel: Sapiens Law, PC.
• Case Identification: 1:26-cv-03308, N.D. Ill., 03/25/2026
• Venue Allegations: Plaintiffs allege venue is proper because the Defendant is not a resident of any U.S. judicial district and previously chose the Northern District of Illinois to enforce the patents-in-suit against Plaintiffs' product line.
• Core Dispute: Plaintiffs seek a declaratory judgment that their PUJIMAX-branded rechargeable batteries do not infringe Defendant's two design patents and, additionally, that those patents are invalid.
• Technical Context: The dispute concerns the ornamental design of rechargeable consumer batteries, a high-volume product category where visual appearance can be a market differentiator.
• Key Procedural History: This action arises from a prior lawsuit (No. 25-cv-15023, N.D. Ill.) where the current Defendant, DLE Tech, sued sellers of Plaintiffs' PUJIMAX products for patent infringement. That case was dismissed on jurisdictional grounds without an adjudication on the merits, which Plaintiffs claim creates the basis for an actual and immediate controversy necessitating this declaratory judgment action.

Case Timeline

II. Technology and Patent(s)-in-Suit Analysis

U.S. Design Patent No. D965,512 - "BATTERY"

• Patent Identification: U.S. Design Patent No. D965512, "BATTERY," issued October 4, 2022.

The Invention Explained

• Problem Addressed: Design patents protect ornamentation rather than solving technical problems. The implicit goal is to create a new, original, and ornamental appearance for a rechargeable battery to distinguish it from others in the market. However, the complaint alleges that the design is substantially dictated by utilitarian needs Compl. ¶66
• The Patented Solution: The patent claims the specific ornamental design for a battery as depicted in its seven figures D'512 Patent, Claim The design consists of a generally cylindrical body with a positive terminal at one end and a flat negative terminal at the other. Its most distinct claimed feature is a recessed, slot-like opening near the positive terminal, which appears to be an integrated charging port D'512 Patent, FIG. 1 D'512 Patent, FIG. 7
• Technical Importance: The design is for rechargeable AA/AAA format batteries, which require standardized dimensions to ensure compatibility with a vast range of electronic devices Compl. ¶66

Key Claims at a Glance

• The single claim asserted is for "The ornamental design for a battery, as shown and described" D'512 Patent, Claim
• The essential visual elements of the claimed design include:
  • A cylindrical battery body.
  • A protruding positive terminal.
  • A specific recessed slot located near the positive terminal, with a distinct shape and orientation.

U.S. Design Patent No. D965,513 - "BATTERY"

• Patent Identification: U.S. Design Patent No. D965513, "BATTERY," issued October 4, 2022.

The Invention Explained

• Problem Addressed: As with the '512 Patent, the goal is to provide a distinct ornamental appearance for a rechargeable battery.
• The Patented Solution: The patent claims the ornamental design for a battery shown in its figures D'513 Patent, Claim This design features a cylindrical body and standard terminals. Its defining characteristic is a recessed, vertically-oriented, pill-shaped cutout near the positive terminal, which appears to house a charging port D'513 Patent, FIG. 1 D'513 Patent, FIG. 7 This cutout differs in shape and proportion from the one shown in the '512 Patent.
• Technical Importance: The design applies to the same field of standardized rechargeable batteries as the '512 Patent, where compatibility is a key functional constraint Compl. ¶66

Key Claims at a Glance

• The single claim asserted is for "The ornamental design for a battery, as shown and described" D'513 Patent, Claim
• The essential visual elements of the claimed design include:
  • A cylindrical battery body.
  • A protruding positive terminal.
  • A recessed, vertically-oriented, pill-shaped cutout located near the positive terminal.

III. The Accused Instrumentality

Product Identification

The "Accused PUJIMAX Products," which are rechargeable batteries sold under the PUJIMAX brand Compl. ¶62 This includes products sold by Plaintiff Luming via the "PUJIMAX Home Local" online storefront and the broader product line sold and distributed by Plaintiff Puji Compl. ¶58 Compl. ¶62

Functionality and Market Context

The products are rechargeable batteries, allegedly of the common AA/AAA form factor Compl. ¶67 The complaint asserts that these products were targeted by the Defendant in a prior patent enforcement action Compl. ¶43 The products are part of what the complaint describes as the "PUJIMAX product ecosystem," sold online by Plaintiffs and their authorized resellers Compl. ¶9 Compl. ¶10

IV. Analysis of Infringement Allegations

The complaint seeks a declaratory judgment of non-infringement and does not contain a detailed, element-by-element infringement analysis from the Defendant's perspective. It makes a broad assertion that the Accused PUJIMAX Products do not infringe the patents-in-suit Compl. ¶79 The complaint's primary focus is on invalidity. Therefore, the complaint does not provide sufficient detail for analysis of infringement allegations in a claim chart format.

• Identified Points of Contention: The complaint raises two primary challenges that will be central to the dispute, both of which relate more to patent validity than to a direct comparison for infringement.
  • Invalidity Based on Functionality: A key issue raised is whether the patented designs are dictated by function rather than ornamentation. The complaint alleges that the standardized cylindrical body, terminal configurations, and charging-port geometry are all driven by "utilitarian purpose and compatibility with existing devices," which may render the designs unpatentable Compl. ¶¶66-67 The complaint provides visual comparisons of the asserted patents to alleged prior art to support its invalidity claims Compl. p. 13 This chart illustrates the similarity between the '513 Patent and the prior art '199 Patent and "BUMP" batteries.
  • Invalidity Based on Prior Art: The complaint explicitly alleges that the patents are invalid as anticipated or obvious in light of prior art that was publicly available before the patents' April 1, 2021 filing date Compl. ¶59 It identifies specific prior art, including Chinese design patents and commercially available products sold on Amazon, and provides a visual comparison chart to illustrate the alleged similarities in overall visual impression Compl. ¶61 Compl. ¶65 Compl. p. 13 The chart on page 13 of the complaint also shows the '512 Patent alongside the prior art '263 Patent and "paleblue" batteries Compl. p. 13

V. Key Claim Terms for Construction

In design patent litigation, claim construction focuses on the overall visual appearance rather than discrete text. The central issue is often filtering out functional elements from the claimed ornamental design.

• The Term: "The ornamental design for a battery"
• Context and Importance: The entire case will turn on the scope of the claimed "ornamental design." Practitioners may focus on this issue because if the court determines that key features (such as the charging port's shape and placement) are primarily functional, those features will be given little to no weight in the infringement and validity analyses. This could significantly narrow the scope of patent protection.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation (More Ornamental): The patentee would point to the patent figures themselves, where the battery's features, including the specific shape, size, and location of the recessed charging port, are depicted in solid lines, indicating they are part of the claimed design D'512 Patent, FIG. 1 D'513 Patent, FIG. 1 The argument would be that the precise execution of these features was an aesthetic choice, not a functional necessity.
  • Evidence for a Narrower Interpretation (More Functional): Plaintiffs argue that features like the "overall cylindrical AA/AAA form factor, terminal configuration, and charging-port placement and geometry are driven by the article's utilitarian purpose" Compl. ¶67 The complaint specifically suggests that the shape of the charging port reflects a "routine functional adaptation to prevailing connector standards" (e.g., Micro-USB or USB-C), rather than "protectable ornamental innovation" Compl. ¶67

VI. Other Allegations

The complaint is a declaratory judgment action for non-infringement and invalidity and does not contain allegations of indirect or willful infringement.

VII. Analyst's Conclusion: Key Questions for the Case

• The Functionality Doctrine: A core issue will be whether the patented designs are invalid because they are dictated by function. The court will need to determine if features like the battery's cylindrical shape and the charging port's configuration are utilitarian elements that must be filtered out of the design patent analysis, or if they represent protectable ornamental choices.
• Invalidity Over Prior Art: A central evidentiary question will be whether the overall visual impression of the '512 and '513 Patents is substantially the same as, or would have been obvious in light of, the prior art asserted in the complaint. The outcome will depend on a visual comparison between the patented designs and prior products like the "BUMP" and "paleblue" batteries.
• The Ordinary Observer Test: If the patents survive the validity challenges, the ultimate question of infringement will be whether an ordinary observer, familiar with the prior art, would be deceived into believing the accused PUJIMAX products are the same as the patented designs.